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Complaints about vs calls for regulations - electronic conspicuity

There seems to exist two factions of pilots in Europe (and certainly on this forum) comprising about ?? % of all of us (no idea what that % is):
- those that moan and complain about the increasing burden of regulations
- those that propose solving all issues through new regulations

Let’s take the electronic conspicuity discussion (transponder in general, ADS-B Out/In, FLARM, PilotAware, … ) as an example. It has raised its head again in the context of the Mallorca accident.

There is an ongoing debate about the future of ADS-B in Europe triggered perhaps in part by the new US regulations WEF 2020.01.01. The arguments and proposed solutions seem to cover the whole spectrum of flying devices, technology, regulation, airspace, etc. What strikes me is the apparent focus on eventual regulation requiring equipping and activation across that spectrum and various airspaces. The discussion is not only here but in various pilot organizations and countries.

What I’m getting at is the unfortunate wait-and-see attitude by all the user groups (individual and organizational) and an apparent feeling of fatality about the regulatory future in this area. That attitude might be realistic, and such a future will likely result in a similar regulatory patchwork mess that that was 8.33MHz.

I would suggest that a better solution for Europe pilots as a group would be to have user organizations come together to form a project to gather options and define a technical proposal with potential for all users. The thinking is to generate a ground-swell rollout that creates a fait-accompli before an expensive top-down regulatory dictate that is unevenly applied across Europe and drives more users to other activities.

There has been some fine work along various technical lines: FLARM, PilotAware, uAvionics/ADS-B UAT, etc. It is still not too late for one solution to be agreed that would be affordable by all users via various models of equipment, provided it had wide backing and support including a strong unified push for voluntary deployment. For example, if all national AeroClubs, AOPAs, experimental groups, UL groups, ballon groups, glider groups, drone activists, etc were to come together behind a single, inexpensive, non-proprietary, out/in technical solution there are a lot of new startups (just wander around AERO) ready and able to roll out products at all price levels for the various markets. It should be possible to have so many implementations across Europe in a short time-frame (say 2-4 years) that regulators would be only too happy to just take it on board. But the benefits for us all would be already largely achieved through improved conspicuity through volume of installations.

I think that FLARM really missed the boat here and did us all a disfavour by a) focussing primarily on the glider market and b) not releasing the technology to the open source community for other applications. Every company’s implementation can be proprietary, but the fundamental technology necessary for inter-operability needs to be freely available or the volumes will never be achieved. If FLARM had done this to start, the technology might already well have been in every flying device in Europe. That’s just speculation, but I’m sure everyone gets the point.

Some interesting products have been coming out over the last few years, driven by the US environment and therefore not optimized for Europe:

Sentry Mini-ADS-B from uavionix

The ADL line from Sebastian Golze is more adapted to the European market and continuing to evolve in the right direction:
ADL200

Perhaps the discussion should be separated into transmission and reception, with the possibility for one and/or the other either in a single device or independently. Any solution for “in” needs to take into account the reality today in terms of ADS-B Out rollout, as the volume of those transponders will increase literally top-down (in terms of altitude).

Last Edited by chflyer at 26 Aug 12:16
LSZK, Switzerland

First, I would like to know what exactly the ADS-B in the US is supposed to solve. It doesn’t seem to me that it is a “GA only issue” since it is only required for higher airspace, C and up as far as I know? The problem in southern parts of Europe (and UK) seems to be an airspace issue. The right tool for the job is a good principle IMO.

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving wrote:

I would like to know what exactly the ADS-B in the US is supposed to solve. It doesn’t seem to me that it is a “GA only issue” since it is only required for higher airspace, C and up as far as I know?

In the US it’s intended to provide more precise location information to ATC which then allows more aircraft in closer proximity. In exchange it provides traffic and weather info to aircraft. And also, oh by the way, it provides identification of equipped aircraft to the extent that you can get a report on every flight by equipped aircraft from an FAA website… which opens up all kinds of fairly obvious future funding possibilities.

Last Edited by Silvaire at 26 Aug 13:55

LeSving wrote:

It doesn’t seem to me that it is a “GA only issue” since it is only required for higher airspace, C and up as far as I know?

US impact is on airspace users at all levels, GA or otherwise. Class C is from the ground up. The 2nd link below has a video that demonstrates this quite effectively.
Equip ADS-B in the USA
ADS-B Coverage Map – Google Earth Plug-in

LSZK, Switzerland

I think the main issue is that old rule in business: to penetrate a market, you need to come in with a decisive advantage.

And, at the cheap end, nobody is doing that.

There are as many “boxes” as there are forum posters – see e.g. here.

The only system that works properly and would have a chance of deep adoption in the GA community is:

  • everyone using Mode C/S transponders, and
  • everyone having an active TAS/TCAS1 system (Lynx, Avidyne, Garmin)

but the 1st is resisted in some communities and the 2nd costs upwards of 10k to install.

The other approach would be a short range system like FLARM. That would meet the requirements for a lack of visibility to enforcement agencies looking for easy ways to bust people for infringing airspace, while providing mid-air protection. FLARM missed the boat by trying to keep it proprietary, for reasons to do with competitive gliding (but according to some past threads people have found ways around it anyway). And the others are simply too numerous, or use system components for which there is no long term business model (basically anything involving ground stations is just a short term gimmick for getting free promotion on pilot forums).

We may all get mandatory ADS-B out one day but I can’t see it happening in Europe, beyond what has happened with Mode S. That is basically what the US has done: certified ADS-B OUT in all TXP-mandatory spaces. What may happen in Europe (the UK CAA is sort of sniffing around in this department) is allowing uncertified ADS-B OUT but ATC can never make use of that (except highly unofficially, to locate offenders whose tracks can then be looked up on radar) so it would be usable only for mid-air protection.

The final crunch is that a certified ADS-B IN system (basically almost anything that is neatly panel mounted and integrated in the avionics, with verbal warnings etc) will never receive uncertified ADS-B OUT. That is just how the world is set up. One could achieve anything with an illegal converter like this but marketing it would be difficult.

So I think the whole system is stuffed and nothing will happen – until we get a wide adoption of certified ADS-B OUT and that is never likely to be more comprehensive than Mode S…

Administrator
Shoreham EGKA, United Kingdom

FLARM is optimised for gliding, so it’s never going to “catch the boat” anyway in powered flying, and they have no intention of doing so as far as I can tell.

Certified ADS-B and TAS/TCAS is just a non-starter for most GA, it’s far too expensive and mid-air collisions are sufficiently rare no one feels it worthwhile. The only way you’ll get wide adoption of anything that gives traffic advisories in light GA, is make it integrate with Skydemon et al. and make it cost less than £300.

I would disagree with ground stations being a short term gimmick. The OGN has been around for a while, is not going away any time soon, and they are now doing Mode-S multilateration.

Andreas IOM

Peter wrote:

We may all get mandatory ADS-B out one day but I can’t see it happening in Europe, beyond what has happened with Mode S.

I’m not so sure. Canada is moving to require use of ADS-B Out receivable by Aireon for ATC purposes to replace radar, as in the US but without the ground station investment which would be prohibitive for the Canadian low-density geography. This is causing a big stir with COPA (Canadian AOPA) due to the current huge expense of antenna diversity. BUT, uAvionix is moving fast to have an inexpensive model meeting that requirement and an low-cost ADS-B Out diversity solution could eliminate entirely the need for ELTs if at the same price-point or less. 8.33MHz requirement came very fast once it started to gain regulatory momentum, as mentioned from top-down (altitude). The same could happen with ADS-B Out, especially in CAT with the presence of Aireon. Once all the airliners have it, there will be pressure to have GA conform.

Peter wrote:

The only system that works properly and would have a chance of deep adoption in the GA community is:

everyone using Mode C/S transponders, and
everyone having an active TAS/TCAS1 system (Lynx, Avidyne, Garmin)
but the 1st is resisted in some communities and the 2nd costs upwards of 10k to install.

1 is largely a UK phenomena in Europe, with much less resistance to position transmission elsewhere. There is also resistance in the US, but it is addressed with the anonymous UAT version of ADS-B Out (which meets the 2020 requirement). I think widespread drone deployment, if it happens, could change the game here from a regulatory standpoint.

2 is indeed a solution for essentially retractible/150kt aircraft and up due to the cost. But traffic input (including ADS-B In) if not mandated can be obtained uncertified as today with various “portable” solutions. Sure, there are those that want this info in the panel (==> via certified units), but not everyone will want or need to pay the price. There are also signs that the proliferation of very useful portable solutions is putting pressure on regulators to lighten restrictions on connectivity to in-panel equipment for display purposes. This needs to continue.

I started this thread after reading comments here about the regulators needing to get busy following the occasional midairs. I think the discussion is important to show that there is interest in the pilot population for solutions that could be widely implemented at low cost. Either the user communities need to “solve the problem” through innovation and supply and demand, or the regulators could well bring down the hammer with high cost solutions that are just another nail in the GA coffin.

LSZK, Switzerland

When everyone got mode S, just open FR24 on your phone/tablet, and you have them all visible with speed and alt and whatnot. In fact, my passenger did that when flying the Cub this weekend to a fly-in. The Cub only has mode C, but he saw other aircraft.

The elephant is the circulation
ENVA ENOP ENMO, Norway

chflyer wrote:

I would suggest that a better solution for Europe pilots as a group would be to have user organizations come together to form a project to gather options and define a technical proposal with potential for all users. The thinking is to generate a ground-swell rollout that creates a fait-accompli before an expensive top-down regulatory dictate that is unevenly applied across Europe and drives more users to other activities.

Clap…clap…clap

Antonio
LESB, Spain
9 Posts
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